Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) Policy
1. Introduction and Commitment
Artemisia Fine Arts & Antiques is committed to complying with all applicable Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) legislation in our jurisdiction, Malta, European Union. We recognize that high-value movable goods, such as antiques and fine art, can be vulnerable to money laundering and terrorist financing.
This policy outlines the measures taken by our business to mitigate these risks and maintain the highest standards of integrity and transparency.
2. Scope and Threshold
This policy applies to all transactions and series of linked transactions concerning the sale, purchase, or storage of antiques or fine art that meet or exceed the statutory threshold of €10,000.
3. Risk-Based Approach
We apply a risk-based approach to all transactions. Factors that increase risk include:
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Use of cash or complex payment structures.
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Transactions involving Politically Exposed Persons (PEPs) or entities from high-risk jurisdictions.
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Transactions where the client shows an unusual lack of interest in the item's provenance, condition, or market value.
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Transactions involving corporate entities or trusts with non-transparent beneficial ownership.
4. Customer Due Diligence (CDD)
For all transactions meeting the specified threshold, and for any transactions deemed high-risk regardless of value, we will perform mandatory Customer Due Diligence (CDD) before the contract is concluded.
A. Customer Identification: We will require and verify the identity of the physical person with whom we are dealing. This requires:
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For Individuals: A valid government-issued photographic ID (e.g., passport or driving license) and proof of residential address.
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For Corporations/Trusts: Documentation to establish the legal existence and identity of the entity, and the verification of the identity of all ultimate Beneficial Owners (persons who ultimately own or control more than 15% of the entity).
B. Source of Funds: We reserve the right to request documentation (e.g., bank statements, professional letters) to establish the legitimate Source of Funds for high-value transactions. Failure to provide satisfactory documentation may result in the refusal of the transaction.
5. Record-Keeping
We will maintain comprehensive records, stored securely and confidentially, for a period of five years from the date the transaction is completed. These records include:
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All CDD information and verification documents.
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Details of the transaction (price, item description, date).
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Any internal reports of suspicious activity.
6. Training and Compliance Officer
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Nominated Officer: The ultimate responsibility for this policy rests with Mrs. Christina Thompson.
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Training: All relevant staff members are trained to recognize and report potential "red flag" indicators of money laundering.
7. Reporting Obligations
We are legally obliged to report any suspicion of money laundering or terrorist financing to the FIAU.
MISSION STATEMENT
As custodians of heirlooms and purveyors of objects of timeless beauty, excellence, and intrigue, we aim to provide our clients with a unique in-store experience.
As art experts and consultants, we offer our knowledge on collection management, art research, and valuations to anyone wishing for an impartial opinion on the value of all types of artworks and antiques, for the purpose of estate division, insurance claims, and auction submission.
As aesthetes, we work tirelessly to promote our passion for beautiful living, inform choices, and promote craftsmanship, creativity, active learning, and self-discovery.
And as members of the wider cultural community, we collaborate with local and international academic institutions, cultural agencies, and art professionals for the improvement of society and as an investment in future generations.
ABOUT ARTEMISIA
At Artemisia, you will find a superbly curated collection of fine art, antiques, curiosities, and home decor spanning the length of human existence and from across the globe. The collection strives to represent Man’s capacity for genius, creativity, and his deep desire to connect and reflect beauty and sublimity, sensations that are often fleeting and drowned out by the mundanity of everyday life.
For this reason, a high street outlet was never an option. At Artemisia, we strive to indulge (or overwhelm) one’s sensibility. We want to make hearts race faster, eyes look longer and deeper, and minds open and fire up. For this reason, we chose to operate from the little village of Bidnija, nestled between the beautiful and lush countryside that borders Burmarrad, Mgarr and Wardija, a place where time seems to stand still.
No expenses have been spared to create a venerable space worthy of its collection. With ample natural light, limitless parking options, expert art lighting, state-of-the-art conference facilities, beautiful and extensive surrounding gardens, and space for entertaining, Artemisia has set a new precedent for the Maltese islands.
The gallery welcomes cultural professionals and students, home lovers, collectors, savvy designers, investment agents, event organizers, and anyone looking for that very, very special gift. Outside of our event schedule, visiting is strictly by appointment and requires I.D. submission.
PLEASE BOOK YOUR VISIT IN ADVANCE.
ABOUT CHRISTINA (BUSUTTIL) THOMPSON
From a very young age, Christina was already sensitive to fine interiors, history, and art; she credits her mother and grandmother for fostering her passions and her father for financially supporting her studies and ambitions.
Christina’s academic expertise consists of several degrees and professional courses, namely her B.A (Hons) in Archaeology & Theatre Studies, an M.Litt in History of Art & Art-World Practice: Fine and Decorative Art from the Renaissance to Modern with Merit (Christie’s London), and a Post-Graduate Diploma in Art Law & Business (Christie’s London). She also has participated in multiple professional development courses accredited by The Victoria & Albert Museum (London).
She worked in the family business at a young age, starting out as a clerk and eventually becoming a manager in the Wines & Spirits department. Whilst working here she was offered the position of International Brand Ambassador by her largest supplier- an experience she treasures as one of the best till today.
Christina’s vision for Artemisia was to create a space whose underlying principle reflected Wagner’s concept of the ‘Gesamtkunstwerk’– a total work that ultimately reflects harmony across all of its aspects, whether visible or unseen. She set up the business in 2015 and has been collecting and trading precious works of art ever since. Her underlying curatorial approach for the Artemisia Collection was to bring together artworks from across the globe (spanning all periods and styles) that demonstrate exquisite workmanship, unique perspectives, are in great condition, and display the values/ zeitgeist of their time whilst being great conversation pieces, offering good provenance, and are unique on the Island making them investment-worthy pieces.
Christina’s prime interests include (but are not limited to) paleontology, natural history, art therapy, neuroaesthetics, the study of the sublime, and the Grand Tour.
